Privacy Confidentiality and Disclosure
Sureway (referred to as “us”, “we” or “our”) is committed to protecting the privacy of the personal information that we collect from you, respecting your rights to privacy and complying with the Privacy Act 1988 (Cth) (the “Privacy Act”).
This policy applies but is not limited to:
- Sureway employees
- Other third parties
This policy also ensures Sureway complies with the National Standards of Disability Service.
When used in this policy, the term “personal information” has the meaning given to it in the Privacy Act. Personal information includes information or an opinion about an identified individual, or an individual who is reasonably identifiable from the information or opinion. In summary, personal information is any information about you that can be linked to you.
The personal information collected may consist of your name, address, telephone number, photo, email address, age or birthdate, company or educational affiliations, profession or occupation, qualifications, titles, contact information, information from your CV, employment records, details of our services you have used or enquired about and other information about you.
Sensitive information is a specific category of personal information. Such information includes membership of a profession or trade association or of a trade union, health information, criminal record and the like. We may need to collect, hold and disclose sensitive information about you in relation to the specific requirements of your placement with our clients or direct engagement by us or to provide you with services. If we do, we will get your specific consent to the collection and use of this information.
We may collect some information that is not personal information because it is not linked to you or any other identifiable person. This may include aggregated information about how users use the Sureway Site, anonymous answers to surveys and other information that is not linked to your identity.
We collect your personal information directly from you unless it is unreasonable or impracticable to do so. We can also collect personal information in a variety of ways, including via the Sureway website (such as when users register or apply for employment), when you respond to e-mail questionnaires or when you provide personal information to us by other means, such as in-person during conversations with our representatives, via your employer for the purposes of providing services to your employer, providing a business card, over the phone or by email.
Sureway has a 1300 number which will be monitored. Therefore there may be times when phone calls are recorded and this can be for a variety of reasons including but not limited to research, quality, training or security purposes.
We may also collect personal information from third parties including:
- our service providers;
- business affiliates;
- clients; and
- Other third parties such as employers and persons nominated by you as referees, credit agencies or government
Personal information is held by us in secure physical and electronic data systems. We will ensure that no personal details are ever displayed in any format in our offices. Whiteboards may only display first initials of the job seeker, unless explicit permission has been provided by the job seeker. All personal information must align with Sureway’s Standard Operating Procedure – Records Management.
We collect personal information about you so that we can perform our business activities and functions and to provide the best possible quality service to you. We collect, hold and disclose your personal information for the following purposes (in some cases we may only disclose information with your consent):
- to provide our services to you and or your prospective employer, including to fulfil your requests for information and employment opportunities and to manage the job services for third parties and ourselves;
- to manage our client and business relationships;
- to provide you important work related information including workplace health and safety, work rosters and other information relating to your engagement by Sureway;
- to undertake psychometric testing;
- to perform statistical analyses of user behaviour in order to measure interest in specific areas and articles posted on the Sureway The e-mail addresses provided at registration allow us to send e-mails to individuals based on the areas of interest that they may indicate during the employment registration process;
- to send communications requested by you, answer enquiries and provide information about existing or new services;
- to provide your updated personal information to related bodies corporate, our customers, contractors or service providers if such disclosure is required to administer our business functions or to provide our products and services to you;
- to update our records and keep your records up to date;
- to process and respond to any complaint made by you; and
- to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in cooperation with any governmental authority of any
We will not intentionally disclose (and will take commercially reasonable steps to prevent the accidental disclosure of) your personal information to third parties, whether for such third parties’ marketing purposes or otherwise, except when we believe we are under a legal duty to do so.
Sureway is obligated to ensure each job seeker or employer is aware that their personal information may be disclosed and passed on to relevant government Department and to other persons in relation to conducting of the services being provided to the job seeker.
Authorisation from the job seeker or employer must be obtained before any disclosure to third parties occurs. Information may be disclosed where there is knowledge of criminal activity and/or an incident that indicate risk of harm to the job seeker.
If we are unable to collect your personal information, we may be unable to fulfil some or all of the purposes listed above. In particular, we may be unable to provide our services to you or provide you with full access to the Sureway Site.
We may disclose your personal information to:
- Department of Employment, Skills, Small and Family Business
- Department of Social Services
- Contractors or service providers if such disclosure is required to administer our business functions or to provide our products and services to you;
- Our employees, related bodies corporate, contractors or service providers for purposes of operation of our website and to fulfil your requests including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors and professional advisors such as accountants, solicitors, business advisors and consultants;
- Any organisation for any authorized purpose with your express consent
You may request access to any personal information we hold about you at any time by contacting us. Where we hold information that you are entitled to access, we will try to provide you with a suitable means of accessing it (for example, by mailing or emailing it to you). We will not charge for making the request or for making any corrections to your personal information. To do so, please contact your Sureway representative or our Risk Audit and Compliance Manager by the means set out in Section 8. We will then contact you to request sufficient information to allow us to confirm your identity. As soon as practicable after your request is received, we will give you access to your personal information.
There may be times when we cannot grant you access to the personal information we hold. For example, if access would interfere with the privacy of others or if it would result in a breach of confidentiality or law, we will not be required to grant you access. We will let you know if this is the case.
If you believe that the personal information we hold about you is incorrect, incomplete or inaccurate, you may request us to amend it by contacting our Risk Audit and Compliance Manager. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it. You may also have your personal information deleted. You should be aware that we are required by law to retain certain personal information (such as payroll records); such information will not be deleted. We will let you know if we cannot delete your personal information for legal or other reasons.
Personal information is destroyed or de-identified when no longer needed.
As the Sureway website is linked to the internet and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any information which you transmit to us online is transmitted at your own risk.
8. Contact our Risk Audit and Compliance Manager